Tax Controversy and Dispute Resolution

• Identifying tax risk potential by evaluating tax positions
• Assistance in litigation before the tax authorities, tribunals and courts
• Ensuring that the position taken before the appellate authorities takes into account impact on subsequent years
• Ensuring expert deliverable representation before appellate authorities
• Having the latest and last-minute legal back-up to be covered in hearing
• Proactively taking advance ruling on income tax implications of transactions
• Solving tax issues under dispute and resolving mechanism
• Ensuring if the competent authority process under the mutual agreement procedure helps you effectively
• Ensuring your tax process is robust enough to handle long-term litigation

We can advise and assist in the following:

• Analysing and optimising alternative remedies for dispute resolution
• Drafting grounds of appeal and other submissions for effective understanding of facts by the authorities
• Effectively complying with appellate requirements and procedures
• Preparing applications and representing them before the Authority for Advance Rulings (AAR) for an advance opinion on the likely tax implications of transactions involving non-residents and international transactions
• Preparing the case and representing it before the appellate authorities, i.e., CIT(A) and ITAT.
• Helping draft and present applications to the competent authority for mutual agreement procedure (MAP) under DTAA
• Reviewing pending litigation and other uncertain tax positions, to comment on adequacy of defence, probability of success and prevention of recurrence
• In-house service of the expert counsel with experience in counsel practice
• Assisting the legal counsel in preparing or representing for appeals, writ petition and special leave petition before the courts